Comments for | Alliance for the Defeat of Citizenship Taxationhttp://citizenshiptaxation.ca
Dedicated to ending the immoral and unjust U.S. place of birth taxationSun, 18 Nov 2018 12:33:07 +0000hourly1https://wordpress.org/?v=4.7.11Comment on John Richardson and Monte Silver: The Sec. 965 Transition Tax & Sec. 951A GILTI Taxes – Next steps by Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax | Citizenship Counselling For U.S. Citizens in Canada and Abroadhttp://citizenshiptaxation.ca/john-richardson-and-monte-silver-the-sec-965-transition-tax-sec-951a-gilti-taxes-next-steps/#comment-8198
Sun, 18 Nov 2018 12:33:07 +0000http://citizenshiptaxation.ca/?p=132113#comment-8198[…] On November 15, 2018 I did a second interview (first interview October 16, 2018 here) with Monte Silver and his Sec. 965 advocacy. The video was featured on a post at CitizenshipTaxation.ca. […]
]]>Comment on Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax” by Part 11: Responding to the Sec. 965 “transition tax”: Letter to the Senate Finance discussing the effects of the transition tax on Americans abroad | Citizenship Counselling For U.S. Citizens in Canada and Abroadhttp://citizenshiptaxation.ca/part-2-the-transition-tax-is-resistance-futile-the-possible-use-of-the-canada-u-s-tax-treaty-to-defeat-the-transition-tax/#comment-7797
Sat, 05 May 2018 12:19:50 +0000http://citizenshiptaxation.ca/?p=96656#comment-7797[…] http://citizenshiptaxation.ca/part-2-the-transition-tax-is-resistance-futile-the-possible-use-of-the&#8230; […]
]]>Comment on Part IV-Sec 965 Transition Tax – Comparing Treatment of Homeland Americans to the Treatment of Non-Residents by Part 10: Responding to the Sec. 965 “transition tax”: Individuals subject to U.S. state tax jurisdiction, the response of New York State | Citizenship Counselling For U.S. Citizens in Canada and Abroadhttp://citizenshiptaxation.ca/part-iv-sec-965-transition-tax-comparing-treatment-of-homeland-americans-to-the-treatment-of-non-residents/#comment-7791
Tue, 24 Apr 2018 12:49:30 +0000http://citizenshiptaxation.ca/?p=103201#comment-7791[…] assets). If you are a U.S. citizen why are living outside the USA anyway?). See in particular Part 4 […]
]]>Comment on Part 9-1: Responding to the Sec. 965 “transition tax”: From the “Pax Americana” to the “Tax Americana” by Transition Tax From the “Pax Americana” to the “Tax Americana”http://citizenshiptaxation.ca/part-9-1-responding-to-the-sec-965-transition-tax-from-the-pax-americana-to-the-tax-americana/#comment-7786
Fri, 20 Apr 2018 02:50:24 +0000http://citizenshiptaxation.ca/?p=109513#comment-7786[…] Part 9-1: Responding to the Sec. 965 “transition tax”: From the “Pax Americana” to t… […]
]]>Comment on U.S. Tax Culture Sees Individual Using a Small Corporation as a “Presumptive Tax Cheat” by The Isaac Brock Society | Part 5: Responding to the Sec. 965 “transition tax”: Shades of #OVDP! April 15/18 is your last, best chance to comply!http://citizenshiptaxation.ca/u-s-tax-culture-sees-individual-using-a-small-corporation-as-a-presumptive-tax-cheat/#comment-7771
Wed, 21 Mar 2018 07:00:59 +0000http://citizenshiptaxation.ca/?p=84950#comment-7771[…] *As a reminder, as explained in this comment, the essential characteristics of the Sec. 965 “transition tax” as applied to the residents of other countries include: […]
]]>Comment on Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax” by The Isaac Brock Society | Part 5: Responding to the Sec. 965 “transition tax”: Shades of #OVDP! April 15/18 is your last, best chance to comply!http://citizenshiptaxation.ca/part-2-the-transition-tax-is-resistance-futile-the-possible-use-of-the-canada-u-s-tax-treaty-to-defeat-the-transition-tax/#comment-7770
Wed, 21 Mar 2018 07:00:41 +0000http://citizenshiptaxation.ca/?p=96656#comment-7770[…] In both cases, the “programs” result in the confiscation of assets over which the “nonresident’s country of residence” has primary taxing jurisdiction. For example, Canada has primary taxing jurisdiction over Canadian Controlled Private Corporations. This principle is explicitly recognized in Section 5 of Article X of the Canada U.S. Tax Treaty which specifically prohibits the United States from imposing taxation on the “undistributed earnings” of Canadian corporations. The whole purpose of the “transition tax” is to impose U.S. taxation on the “undistributed earnings” …. […]
]]>Comment on Part 3-Responding to the Sec 965 Transition Tax- They Hate you for Your Pensions! by Transition Tax: Shades of #OVDP! your last | best chance to comply!http://citizenshiptaxation.ca/part-iii-responding-to-the-sec-965-transition-tax-they-hate-you-for-your-pensions/#comment-7769
Wed, 21 Mar 2018 06:03:27 +0000http://citizenshiptaxation.ca/?p=102227#comment-7769[…] In the same way that (for Americans abroad) the OVDP program confiscated “after tax paid” assets owned by Americans abroad, the “transition tax” is confiscating after tax paid capital that operates as a private pension plan. […]
]]>Comment on Part IV-Sec 965 Transition Tax – Comparing Treatment of Homeland Americans to the Treatment of Non-Residents by Transition Tax: Shades of #OVDP! your last | best chance to comply!http://citizenshiptaxation.ca/part-iv-sec-965-transition-tax-comparing-treatment-of-homeland-americans-to-the-treatment-of-non-residents/#comment-7768
Wed, 21 Mar 2018 05:52:16 +0000http://citizenshiptaxation.ca/?p=103201#comment-7768[…] Part IV-Sec 965 Transition Tax – Comparing Treatment of Homeland Americans to the Treatment of… […]
]]>Comment on U.S. Tax Culture Sees Individual Using a Small Corporation as a “Presumptive Tax Cheat” by Transition Tax: Shades of #OVDP! your last | best chance to comply!http://citizenshiptaxation.ca/u-s-tax-culture-sees-individual-using-a-small-corporation-as-a-presumptive-tax-cheat/#comment-7767
Wed, 21 Mar 2018 05:44:24 +0000http://citizenshiptaxation.ca/?p=84950#comment-7767[…] *As a reminder, as explained in this comment, the essential characteristics of the Sec. 965 “transition tax” as applied to the residents of other countries include: […]
]]>Comment on Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax” by Transition Tax: Shades of #OVDP! your last | best chance to comply!http://citizenshiptaxation.ca/part-2-the-transition-tax-is-resistance-futile-the-possible-use-of-the-canada-u-s-tax-treaty-to-defeat-the-transition-tax/#comment-7766
Wed, 21 Mar 2018 05:36:28 +0000http://citizenshiptaxation.ca/?p=96656#comment-7766[…] In both cases, the “programs” result in the confiscation of assets over which the “nonresident’s country of residence” has primary taxing jurisdiction. For example, Canada has primary taxing jurisdiction over Canadian Controlled Private Corporations. This principle is explicitly recognized in Section 5 of Article X of the Canada U.S. Tax Treaty which specifically prohibits the United States from imposing taxation on the “undistributed earnings” of Canadian corporations. The whole purpose of the “transition tax” is to impose U.S. taxation on the “undistributed earnings” …. […]
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